OSHA Walking-Working Surface Rule Aims to Prevent Workplace Fall Incidents

by Karen

Employees have the potential to be exposed to fall risks every working day. This problem is not isolated to one type of industry or one type of employee. It is a risk that all employers face.

Same-level falls and falls to lower levels are the second-leading cause of lost work time injuries and deaths, respectively, in the United States. To help decrease the nearly 6,000 injuries and 30 deaths annually due to falls, the Occupational Safety and Health Administration (OSHA) published a final rule on November 18, 2016, that improves walking-working surface rules and establishes a fall protection standard for general industry.

Summary of Major Changes

All walking-working surfaces must be inspected regularly to ensure they are free of contaminants, defects or other imperfections that could contribute to a slip, trip or fall injury
Any walking-working surface hazards that are discovered must be corrected or guarded to prevent anyone from walking on them until the hazard is removed
Requirements for all types of ladders have been revised and consolidated
Vertical clearances in stairways have been modified
Scaffold requirements now mirror those used in construction industries
Requirements for the use of Rope Descent Systems have been added
Employers now have more options to guard fall-from-height hazards
New performance, care and use criteria for all personal fall protection systems has been added

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The History

Revisions to the walking-working surface standard were first proposed in 1990. They were revised in 2003 and re-proposed in 2010. The final rule is applicable to all general industry employers and covers a variety of walking-working surfaces including:

Floors
Ladders
Stairways
Runways
Dockboards
Roofs
Scaffolds
Elevated work surfaces
Walkways

Incorporating best practices from more than 30 industry consensus standards, the rule is performance based, giving employers greater flexibility to correct walking-working surface hazards in a manner that best suits their workplace and working conditions. General industry workplaces now also have specific fall from height rules that closely mirror the fall from heights regulations that have been preventing construction injuries and deaths for decades.

Walking-Working Surfaces Defined

All general industry workplaces and walking-working surfaces are covered under the rule, unless they have been specifically excluded. OSHA defines a walking-working surface as:

“Any horizontal or vertical surface on or through which an employee walks, works or gains access to a work area or workplace location.”

In this definition, OSHA clarifies that it is not just floors where workers perform a work duty. Building entrances, hallways, aisles, breakrooms, locker rooms, cafeterias and other areas in and outside the facility are also included.

Slips and falls to the same level can occur anywhere. This increased definition of what constitutes a walking-working surface should prompt employers to be more aware of the need to take a facility-wide approach to fall prevention and not isolate efforts solely to production or other areas of their facility.

General Requirements [29 CFR 1910.22]

Since the first walking-working surface rule was published in the early 1970s, employers have been required to maintain their workplace in a clean, orderly and sanitary condition. Specifically, workroom floors have always been required to be kept clean and dry. In areas that can’t be kept dry, OSHA required mats, platforms or elevated work surfaces.

The revised rule maintains these requirements and qualifies that hazards such as “sharp or protruding objects, loose boards, corrosion, leaks, spills, snow and ice” must also be prevented.

To help ensure that walking-working surfaces remain free of recognized hazards, employers are now required to inspect all areas regularly. When hazards are discovered, they must be corrected immediately. If they cannot be corrected immediately, they must be guarded to prevent anyone from walking on them until the hazard can be eliminated.

Throughout the rule, emphasis is placed on ensuring that all walking-working surfaces (including floors, ladders and dockboards) are capable of supporting their maximum intended loads. Any repairs that affect the structural integrity of a walking-working surface must be made or supervised by a qualified person.

Ladders [29 CFR 1910.23] and Stepbolts [29 CFR 1910.24]

Several different sets of regulations previously governed various types of ladders. Now, all types of ladders (portable and fixed, wood, metal, composite, etc.) have a general set of requirements including provisions for:

Rungs, steps and cleats to be parallel, level and uniformly spaced with minimum clearances from obstructions
Corrosion resistance
Inspections
Defective ladders to be removed from service
Climbing and descending ladders
Safe use

Additionally, portable ladders, fixed ladders, mobile ladder stands and mobile ladder stand platforms each have more specific requirements applicable to the particular type of device being utilized. OSHA hopes that the changes, which align rules with several consensus standards, will help improve clarity and provide flexibility in compliance efforts.

Stepbolts also allow workers to climb from one level to another. Like the requirements for ladders, stepbolts must be evenly spaced and corrosion-free. They must also be designed in a manner to prevent slipping. These design requirements, along with updated strength provisions will increase worker safety while they are climbing or standing on stepbolts.

Stairways [29 CFR 1910.25]

A majority of the existing requirements for stairways were maintained in the final rule. Similar to the previous requirements, standard, spiral, ship and alternating tread stairs must have handrails, uniform riser heights and tread depths. The new rule decreases the vertical clearance from 7 feet to 6 feet, 8 inches to make it consistent with other consensus standards.

Dockboards [29 CFR 1910.26]

Dockboards are portable or fixed devices that “span a gap or compensate for a difference in height between a loading platform and a transport vehicle.” They include bridge plates, dock levels and dock plates. Like other sections, dockboards must be capable of supporting their maximum intended load.

Employers must ensure safety by having a means of preventing workers from driving off of the dockboard, as well as preventing transport vehicles from moving while they are being accessed.

Scaffolds and Rope Descent Systems (RDS) [29 CFR 1910.27]

Previous standards addressed the use of scaffolds in general industry, but did not make provisions for rope descent systems (RDS). Although both involve working at heights, because the hazards of working on a scaffold are different than working on an RDS, each is addressed by different paragraphs.

Scaffolds used in general industry must meet the same requirements as scaffolds used in construction. This allows for consistency, regardless of where an employee works.

Existing general industry and construction standards did not address the use of RDS, which are common in window and building cleaning industries. There was, however, a memorandum issued in 1991 that had been used to provide guidance. The final rule incorporates the provisions of this memorandum, including anchorage requirements that must be verified, protecting ropes, not using RDS in hazardous weather conditions and limiting its use to 300 feet.

Duty to Have Fall Protection [29 CFR 1910.28]

The first of three new sections, general industry employers must now evaluate all areas and operations in their facility to identify fall hazards. Where hazards are found, engineering controls, administrative controls and/or personal fall protection systems must be used to prevent injuries and deaths.

Under existing general industry regulations, employers were required to use guardrails to prevent fall hazards. The new rule, which requires employers to provide protection any time a worker is four or more feet above a lower level, is performance based, recognizing that there are many ways to guard against fall from height hazards. Employers may use any effective method including:

Guardrail systems
Safety net systems
Personal fall protection or fall arrest systems
Travel restraint systems
Ladder safety systems
Positioning systems
Handrails
Designated areas (on low-slope roofs)

There are four exemptions to the four-foot-height trigger, including the use of motorized equipment on dockboards; overly dangerous equipment such as vats, tanks and machinery; around repair, service and assembly pits; and on fixed ladders less than 24 feet.

Employers must also prevent falling objects from hitting workers. To achieve this, head protection is required in areas where objects may fall. Employers must also use toeboards, screens, canopies or barricades for additional protection.

Fall Protection Systems and Falling Objects Protection [29 CFR 1910.29]

Employers must take a “proactive approach” to managing fall protection systems. This includes installing fall protection systems that are properly designed and tested. Systems must withstand applied force, corrosion and other factors that could cause failure and contribute to a worker injury or death.

Fall Protection Systems [29 CFR 1910.140]

The new personal Fall Protection Systems regulations establish performance, care and use criteria for all personal fall protection systems. Body harnesses, connectors, lanyards, snap rings, lifelines, anchors and all other devices must meet applicable performance requirements. Much of this final rule mirrors the requirements in the construction standard, as well as many recognized industry consensus standards that have already been proven to effectively minimize hazards and prevent incidents.

Fall Protection Training [29 CFR 1910.30]

Workers who may be exposed to fall hazards must receive training on where those hazards exist and what procedures are in place to prevent incidents. If personal fall protection systems will be used, employees must also be trained on how to use, install, inspect, operate, disassemble and maintain them properly.

Training must be designed and conducted by a qualified person, although OSHA permits multiple training formats such as classroom, audio-visual, demonstrations, and computer-based training. Employees must receive training in a format that they understand.

Retraining must occur when:

There are changes to the workplace
There are changes to the type of fall protection systems or equipment used
A worker’s knowledge of how to use fall protection equipment is inadequate
A worker is involved in an incident or near miss
A worker performs a job in an unsafe manner
A worker receives a poor evaluation

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TAGS: Safety, Slips Trips and Falls

1 Comment

Taylor Andersonsays:
09/04/2018 at 11:07 am Reply
I like how you said personal fall protection systems can help protect employees and employers. My brother does a lot of odd jobs, so sometimes I get really worried about his safety. I’ll share this article with him, so he can make sure his work is helping him from falling and injuring himself.

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